jll1 Privacy Policy

1. Who We Are

jll1 ("the Platform," "we," "us," or "our") is an online gaming platform operating at jll1.cam, serving Filipino players under PAGCOR (Philippine Amusement and Gaming Corporation) regulatory oversight. For the purposes of Philippine Data Privacy Act of 2012 (Republic Act No. 10173), jll1 acts as the Personal Information Controller (PIC) in respect of personal data collected from registered players and platform visitors.

As a Personal Information Controller, jll1 determines the purposes and means of processing personal data collected through the Platform. We have designated a Data Protection Officer (DPO) who oversees compliance with the Data Privacy Act and serves as the primary point of contact for data rights requests. Contact details for our DPO are provided in Section 14 of this policy.

2. Scope of This Policy

This Privacy Policy applies to all personal data collected and processed by jll1 through the following channels:

• Registration and account management on the jll1 website (jll1.cam)
• Real-money gaming activity, including sports betting, live dealer games, slots, and bingo
• Financial transactions including deposits via GCash, Maya, BPI, BDO, Metrobank, and other supported payment methods
• Customer support interactions via live chat and email
• KYC (Know Your Customer) identity and address verification processes
• Marketing communications where you have provided consent
• Technical data collected automatically through cookies and similar technologies when you browse the Platform

This policy does not apply to third-party websites or services that may be linked from our Platform. jll1 is not responsible for the privacy practices of third-party sites. We encourage you to review the privacy policies of any external sites you visit independently of jll1.

3. Data We Collect

3.1 Registration Data

When you create a jll1 account, we collect the following personal information:

• Full legal name as it appears on your government-issued ID
• Date of birth (for 21+ age verification)
• Philippine mobile number
• Email address
• Home address in the Philippines
• Username and encrypted password

3.2 KYC Verification Data

To comply with PAGCOR regulations and the Philippine Anti-Money Laundering Act, we collect the following during identity verification:

• Copy or photograph of a valid Philippine government-issued photo ID (Passport, Driver's License, UMID, SSS/GSIS ID, Postal ID, Voter's ID, PhilSys National ID, or PRC ID)
• Proof of current Philippine residential address (utility bill, bank statement, or government correspondence dated within 3 months)
• Source of funds documentation in certain circumstances as required by AMLA compliance obligations
• Selfie or facial verification image for identity confirmation purposes

3.3 Financial Transaction Data

When you make deposits or withdrawals, we collect and process:

• GCash or Maya account reference numbers (not your full e-wallet credentials)
• Philippine bank account details for withdrawal processing (account name, bank name, account number)
• Transaction amounts, timestamps, and reference numbers
• Transaction history for regulatory reporting and AML monitoring purposes

3.4 Gaming Activity Data

jll1 maintains records of your gaming activity on the Platform, including:

• Game sessions, bet amounts, and game outcomes
• Sports betting selections and settlement results
• Account balance history
• Bonus usage and wagering activity
• Session duration and login timestamps

3.5 Technical and Device Data

When you access the jll1 Platform, we automatically collect certain technical information:

• IP address and approximate geographic location derived from IP
• Device type, operating system, and browser version
• Pages visited, click patterns, and session duration on the Platform
• Referring URLs and search terms used to find jll1
• Cookie identifiers and similar tracking technologies (see Section 7)

4. How We Use Your Data

jll1 processes your personal data for the following specific purposes:

1. Account Creation and Management: To register your jll1 account, verify your identity and age, maintain your account records, process password resets, and provide access to Platform features.
2. PAGCOR Regulatory Compliance: To fulfill obligations under jll1's PAGCOR operating license, including KYC verification, player registration records, and submission of required reports to PAGCOR.
3. Anti-Money Laundering (AML) Compliance: To monitor transaction patterns, flag suspicious activity, and report to the Anti-Money Laundering Council (AMLC) as required under the Philippine Anti-Money Laundering Act (Republic Act No. 9160, as amended).
4. Payment Processing: To process your deposits from GCash, Maya, BPI, BDO, Metrobank, and other supported payment channels, and to process withdrawal requests to your registered payment accounts.
5. Gaming Operations: To facilitate your participation in games, record game results, settle bets, apply bonuses, and maintain accurate account balance records.
6. Responsible Gaming Monitoring: To monitor gaming patterns that may indicate problem gambling behavior and to enforce deposit limits, loss limits, and self-exclusion requests you have activated on your account.
7. Customer Support: To respond to your support inquiries, investigate complaints, and resolve disputes regarding transactions or game outcomes.
8. Security and Fraud Prevention: To detect and prevent unauthorized account access, fraudulent transactions, bonus abuse, collusion, and other prohibited activities described in the jll1 Terms & Conditions.
9. Platform Improvement: To analyze aggregate usage patterns, identify technical issues, and improve the performance and user experience of the jll1 Platform.
10. Marketing Communications: To send you promotional offers, bonus notifications, and platform news — only where you have provided explicit consent. You may withdraw marketing consent at any time via your account settings or by contacting support.

5. Legal Bases for Processing

Under the Philippine Data Privacy Act of 2012, jll1 relies on the following legal bases for processing your personal data:

• Contractual Necessity: Processing required to fulfill the contract between you and jll1 — including account management, payment processing, and gaming operations — is based on contractual necessity.
• Legal Obligation: Processing required to comply with PAGCOR regulatory requirements, the Philippine Anti-Money Laundering Act, the Data Privacy Act, and other applicable Philippine laws is based on legal obligation.
• Legitimate Interests: Processing for fraud prevention, security monitoring, and platform improvement is based on jll1's legitimate interests, balanced against your data protection rights. We conduct a balancing test for each legitimate interest use case.
• Consent: Processing for marketing communications and optional features is based on your explicit consent. You may withdraw consent at any time without affecting the lawfulness of processing prior to withdrawal.

6. Sharing Your Data

jll1 does not sell your personal data. We share personal data only in the following circumstances:

6.1 Regulatory Authorities

jll1 is required by law to share certain personal data and transaction records with PAGCOR (Philippine Amusement and Gaming Corporation), the Anti-Money Laundering Council (AMLC), and other Philippine government authorities upon lawful request or as part of mandatory periodic reporting obligations. These disclosures are not optional and are required to maintain our PAGCOR operating license.

6.2 Payment Service Providers

To process deposits and withdrawals, jll1 shares necessary transaction data with certified Philippine payment service providers including GCash (Mynt), Maya (Voyager Innovations), and Philippine commercial banks. These providers are required to protect your financial data under their own licensing requirements and applicable Philippine financial regulations. jll1 shares only the minimum data necessary for payment processing.

6.3 Technology Service Providers

jll1 engages carefully selected technology partners — including cloud hosting providers, KYC verification services, and game content providers — who may process personal data on our behalf as Personal Information Processors (PIPs). All such providers are bound by data processing agreements that require them to protect your personal data, process it only as instructed by jll1, and comply with Philippine data protection requirements.

6.4 Law Enforcement

jll1 may disclose personal data to Philippine law enforcement agencies where required by a valid court order, subpoena, or other lawful legal process, or where jll1 reasonably believes disclosure is necessary to prevent or investigate fraud, money laundering, or other criminal activity.

7. Cookies & Tracking Technologies

jll1 uses cookies and similar tracking technologies to operate the Platform, maintain your session, and analyze usage patterns. The following categories of cookies are used on the jll1 website:

• Strictly Necessary Cookies: These cookies are essential for the Platform to function. They maintain your login session, remember your account preferences, and ensure the security of your session. These cookies cannot be disabled without impairing Platform functionality.
• Functional Cookies: These cookies remember your Platform preferences such as language settings, preferred game categories, and display options, providing a more personalized experience. Disabling these cookies may affect Platform usability.
• Analytics Cookies: jll1 uses privacy-focused analytics tools to understand how players use the Platform — which pages are visited most often, where players encounter difficulties, and how the Platform can be improved. Analytics data is aggregated and anonymized where possible.
• Security Cookies: jll1 uses cookies to detect and prevent fraudulent activity, including account takeover attempts, bot activity, and multiple account registrations from the same device.

You can manage cookie preferences through your browser settings. Note that disabling strictly necessary cookies will prevent you from logging into your jll1 account. For detailed information on the specific cookies used by jll1, please contact our Data Protection Officer at the details provided in Section 14.

8. Data Retention

jll1 retains personal data for as long as necessary to fulfill the purposes described in this Privacy Policy, subject to the following specific retention periods:

• Account Data: Retained for the duration of your active jll1 account plus five (5) years following account closure, as required for PAGCOR regulatory compliance and potential dispute resolution.
• KYC Documents: Retained for five (5) years following account closure, as required by PAGCOR regulations and Philippine AML law (Republic Act No. 9160, as amended).
• Financial Transaction Records: Retained for five (5) years from the date of each transaction, as required by Philippine AML regulations and PAGCOR reporting obligations.
• Gaming Activity Logs: Retained for three (3) years from the date of each gaming session for dispute resolution and regulatory audit purposes.
• Customer Support Records: Retained for two (2) years from the date of the support interaction.
• Marketing Consent Records: Retained for the duration of your consent plus three (3) years, to demonstrate compliance in the event of a complaint to the National Privacy Commission.

Upon expiry of the applicable retention period, jll1 will securely delete or anonymize your personal data in accordance with data destruction procedures approved by our Data Protection Officer.

9. Security Measures

jll1 implements a layered approach to data security, combining technical safeguards with organizational procedures to protect your personal data against unauthorized access, disclosure, alteration, or destruction. Key security measures include:

• Encryption in Transit: All data transmitted between your device and jll1 servers is protected using TLS 1.2 or higher (256-bit SSL encryption).
• Encryption at Rest: Sensitive personal data including KYC documents, financial details, and account credentials are stored in encrypted databases. Passwords are stored using one-way cryptographic hashing — not even jll1 support staff can view your password.
• Access Controls: Access to personal data within jll1's systems is restricted on a strict need-to-know basis. Staff are granted access only to the data required to perform their specific job function. All data access is logged and audited.
• Two-Factor Authentication: jll1 offers optional two-factor authentication (2FA) via SMS for all player accounts. Players are strongly encouraged to enable 2FA to add a second layer of account security.
• Penetration Testing: jll1 engages independent security firms to conduct regular penetration testing and vulnerability assessments of our systems.
• Staff Training: All jll1 employees with access to personal data receive mandatory data protection training covering DPA 2012 requirements, security procedures, and incident response protocols.

10. Your Rights Under DPA 2012

Under the Philippine Data Privacy Act of 2012, you have the following rights in respect of your personal data held by jll1. To exercise any of these rights, contact our Data Protection Officer using the details in Section 14. We will respond to all data rights requests within fifteen (15) business days.

• Right to Be Informed: You have the right to be informed about how your personal data is collected and processed. This Privacy Policy fulfills this right.
• Right of Access: You have the right to request a copy of the personal data jll1 holds about you, together with information about how it is processed. We will provide this in a commonly used electronic format upon verified request.
• Right to Rectification: You have the right to request correction of any inaccurate or incomplete personal data jll1 holds about you. You can update certain account details directly in your account settings. For KYC-related data corrections, please contact support with updated documents.
• Right to Erasure: You have the right to request deletion of your personal data where it is no longer necessary for the purpose for which it was collected, subject to jll1's legal obligation to retain certain data for regulatory compliance periods as described in Section 8.
• Right to Object: You have the right to object to the processing of your personal data for direct marketing purposes. You may opt out of marketing communications at any time via your account settings or by contacting support.
• Right to Data Portability: You have the right to receive your personal data in a structured, commonly used, and machine-readable format, and to transmit it to another personal information controller where technically feasible.
• Right to Lodge a Complaint: If you believe your data rights have not been adequately addressed by jll1, you have the right to lodge a complaint with the National Privacy Commission (NPC) of the Philippines.

11. Children's Privacy

The jll1 Platform is strictly intended for users aged twenty-one (21) years and above. jll1 does not knowingly collect personal data from individuals under the age of 21. Age verification is a mandatory part of the jll1 registration and KYC process, and accounts belonging to players under 21 will be permanently closed upon discovery.

If you are a parent or guardian and believe that your child under the age of 21 has registered a jll1 account or provided personal data to jll1, please contact our Data Protection Officer immediately at the contact details in Section 14. We will promptly investigate and delete any personal data collected from an underage individual and close the associated account.

12. Cross-Border Data Transfers

In certain circumstances, jll1 may transfer your personal data to service providers located outside the Philippines — for example, cloud hosting providers or game software suppliers with servers in other countries. Where such cross-border transfers occur, jll1 ensures that appropriate safeguards are in place as required by Section 21 of the Data Privacy Act of 2012 and NPC Circular 16-01.

Safeguards for cross-border data transfers may include: contractual clauses that impose data protection obligations on the receiving party equivalent to Philippine DPA requirements; binding corporate rules where applicable; or transfers to countries recognized by the National Privacy Commission as providing an adequate level of data protection. jll1 will not transfer your personal data to a country or entity that does not provide adequate protections without first obtaining your explicit consent.

13. Changes to This Policy

jll1 reserves the right to update this Privacy Policy from time to time to reflect changes in our data processing practices, new regulatory requirements, or improvements to our Platform. Material changes to this Privacy Policy will be communicated to registered players via email to their registered email address and/or via an in-Platform notification at least fourteen (14) days before the changes take effect.

The date of the most recent update is displayed at the top of this document. Your continued use of the jll1 Platform after the effective date of any revised Privacy Policy constitutes your acceptance of the updated terms. If you do not agree to a material change, you have the right to close your account and request deletion of your data (subject to regulatory retention obligations) before the change takes effect.

14. Contact & DPO Details

For all data privacy inquiries, data rights requests, complaints, or questions about this Privacy Policy, please contact jll1's Data Protection Officer using the following channels:

• Email: [email protected] — please include "Data Privacy Request" in the subject line. Responses within 15 business days.
• Live Chat: Available 24/7 on the jll1 Platform. For data rights requests, please ask to be connected to the Data Protection team.

For formal written notices related to data privacy, please send correspondence to the jll1 Data Protection Officer via email at [email protected] with the subject line "Formal DPA Notice." jll1 will acknowledge receipt of formal notices within five (5) business days.

If you believe your data privacy rights have not been adequately addressed after contacting jll1's DPO, you may lodge a complaint with the National Privacy Commission of the Philippines through their official channels. You can find NPC contact details and complaint procedures on the NPC's official government website.